20h • GDPR for Debt Collectors
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I have sent sar 1 sar 2 and sar 3 then I sent a final notice and zinc came back with this reply I am trying to help my daughter get out of a situation she got herself into “template driven internet sourced letter”
ZINC
GROUP LTD
Xxxxxxxx
92 xxxxxx
Xxxxxx
Xxxxx
Xxxx
3rd of February 2026
Zinc Reference: xxxxxx
Re: NatWest Group
Account No: 5xxxxxxxxx
Dear xxxxxxxx
We write further to your correspondence titled "Final Notice - intent to initiate legal proceedings" which appears to be a template-driven, internet-sourced letter. We have carefully reviewed the matters raised and for the avoidance of doubt, we do not agree with your assertions and do not accept that we have acted unlawfully, failed to comply with data protection legislation, or engaged in unauthorised debt collection activity. Our position is set out below and represents our final response on these issues.
Our role and authority
As previously explained on multiple occasions, we act solely as a third-party service provider on behalf of our client. We are not the creditor and have not purchased the account. Accordingly, no Deed of Assignment exists in relation to this account. A Deed of Assignment arises only where a debt has been legally assigned to another party. As no assignment has taken place, your request for a Deed of Assignment under section 136 of the Law of Property Act 1925 and related legislation is misconceived and cannot be complied with.
Our authority to act derives from our contractual appointment by our client, not from any assignment of rights. As will have been stated in our clients' terms and conditions and fair processing notice, our client can pass customer data to a third party such as us for collection of an outstanding balance.
Consumer Credit Act documentation
Requests made pursuant to sections 77-79 of the Consumer Credit Act 1974 apply to the creditor.
As we are not the creditor, but rather a third-party agent, we do not hold the original credit agreement. Therefore, your request for documentation was appropriately referred to our client. You have confirmed within your correspondence that documentation was supplied by our client following your request. We therefore consider this aspect closed
Data protection and Subject Access Requests
We deny any breach of the UK GDPR or the Data Protection Act 2018.
- Your Subject Access Request we received in August 2025 was responded to within statutory time limits.
- All personal data held by us was disclosed.
- Your data has been processed in accordance with our obligations as a data processor acting on our client's instructions.
- In January 2026, we complied with our client's request to provide them with all personal data we hold in relation to you, to assist with a Subject Access Request.
Your proposed legal action
You are entitled to pursue any course of action you deem appropriate; however, we do not accept the 7-day deadline you have set.
Should proceedings be issued, we are confident in our position and will defend any claim robustly.
To clarify:
- We deny any breach of data protection laws.
- We deny any unauthorised debt collection activity
- We deny any entitlement to damages.
Our position has now been clearly and repeatedly set out. We will not enter into further correspondence regarding requests for a Deed of Assignment, the alleged data protection breaches, or the lawfulness of our role, unless required to do so by a court or regulatory authority.
If you believe the creditor has failed to comply with its statutory obligations, those concerns should be directed to them as data controller and creditor. Should we receive further correspondence raising the same points, we may not respond. To avoid misunderstanding, re-sending the same allegations or requests will not change our role, our obligations, or the information we can provide
Should you decide to contact The NatWest Group directly, you can find information on how to do so @ xxxxxxxxxxx
I have placed a 14 day hold on the above noted Zinc account to allow you time to receive and consider this letter. Following this timeframe, you may receive further contact from us with a view to seeking the best way forward in the resolution of the above noted account, in the interest of both yourself and our client. Please be assured we aim solely to assist our customers and welcome a constructive conversation.
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